Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Challenge to the validity of the SCN on the ground that it was issued by an incompetent officer was rejected because, though the portal reflected the Superintendent, the SCN was actually signed by the competent Joint Director; consequently, the SCN was not invalidated. Objection to appellate forum/jurisdiction was rejected as the correct appellate authority was the Commissioner (Appeals), and the impugned DRC-07 was only a portal summary uploaded by the jurisdictional commissionerate based on the highest tax-demand principle in multi-notice adjudications; consequently, the petitioner was relegated to the statutory appeal, with a direction that an appeal filed by 31-01-2026 with pre-deposit shall not be dismissed as time-barred and must be decided on merits. - HC
Challenge to the validity of the SCN on the ground that it was issued by an incompetent officer was rejected because, though the portal reflected the Superintendent, the SCN was actually signed by the competent Joint Director; consequently, the SCN was not invalidated. Objection to appellate forum/jurisdiction was rejected as the correct appellate authority was the Commissioner (Appeals), and the impugned DRC-07 was only a portal summary uploaded by the jurisdictional commissionerate based on the highest tax-demand principle in multi-notice adjudications; consequently, the petitioner was relegated to the statutory appeal, with a direction that an appeal filed by 31-01-2026 with pre-deposit shall not be dismissed as time-barred and must be decided on merits. - HC
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